Ehlers v. Vinal

LAY, Circuit Judge.

Taxpayer instituted this action against the District Director of Internal Revenue for the District of Nebraska to recover an alleged overpayment of income taxes, penalties and interest for the years 1948 through 1958, in the total amount of $122,344.91 plus interest.1

The taxpayer, appellant in this court, is an attorney. This litigation arises from his purchase of various properties in and about Omaha, Nebraska, which were subject to land contracts. At the *61time of the purchase, he would receive from the vendor a blank deed, an abstract of title, an insurance policy on the…